10 minutes to read With insights from... Steven Steer Principal Data Consultant steven.steer@zuhlke.com The UK is facing a major cost of living crisis. Many households are struggling with their rent or mortgage payments, forced to tighten discretionary spending and resort to desperate measures like unplugging fridges to cope with rising bills. Right now, effectively supporting the most vulnerable groups across the country must be a priority. Enter Citizens Advice, a UK-based, independent, consumer charity that specialises in providing advice and assistance to people with legal, debt, housing, and similar problems. Their ground-breaking “Closing the Gap” report outlined their vision for improving consumer support in essential services. The report shed light on the inadequacy of the current approach to data sharing among essential service providers like energy, water, telecoms, and financial companies. It stressed that the customer journey of accessing support is way too complex and disjointed, resulting in people missing out on the support they are entitled to. Additionally, the report outlined what a better system could look like, one that bridges the gap between the support people need and the support they receive. Early last year, our team conducted Innovate UK-funded research, investigating the value and opportunities of effectively working with permissions data that describes individuals’ preferences for the use of their personal information. To continue exploring the subject with industry peers, we held a co-creation session in collaboration with the Open Data Institute (ODI). At the workshop, the topic of supporting vulnerable groups emerged as a priority and sparked a passionate discussion about the ways in which open and therefore trustworthy data ecosystems could facilitate ethical data sharing and improve the current system. Figure 1: Visualisation of consumer journeys for people in vulnerable circumstances seeking support: (left) current journeys, (right) a potential streamlined journey, adopting a shared data architecture. In the interest of furthering progress, we’ve collated the learnings from Citizens Advice’s report, the co-creation session, and our Innovate UK research on personal data sharing. As Citizens Advice point out in their report, more needs to be done to ‘revolutionise the way people access support’ and to ‘achieve a solution that can be used by providers across all essential service sectors’. To do so, Citizens Advice suggests that government intervenes by assembling an ‘Essential Services Industry Taskforce’ that includes key stakeholders like the Information Commissioner’s Office, National Government, Ofgem, Ofcom, Ofwat, the FCA, and Citizens Advice itself. In support of this vision and to accelerate coordination, we’ve outlined a practical roadmap to help explain what activities such a taskforce should prioritise to make the Citizens Advice vision a reality and improve support for vulnerable groups through ethical and collaborative data sharing. Roadmap to an ethical data ecosystem to support consumers in vulnerable circumstances Our suggestion is a three-stage process – learn, design, prototype – however, we do not expect this to be a linear journey. For example, prototyping will stimulate new design work and designing will create a need for additional learning. Fundamental to success will be the inclusive and continuous information sharing among the direct participants of the data ecosystem and with the wider range of stakeholders who have strong opinions over how essential services should operate. This is essential for earning trust in the ethical use of individuals’ personal data within these services and ensuring their willing consent. Here’s what the three-stage process would look like: Figure 2: Suggested roadmap for an Essential Services Industry Taskforce to establish an ethical data ecosystem to create simple and controllable support services for consumers in vulnerable circumstances. 1. Learn This step has already begun as Citizens Advice outlined key essential services and government departments that’ll have to work together. Our co-creation session provided more details on the relevant types of organisations that need to be included: Central government and local authorities Emergency services Debt collection agencies Water and energy networks Energy retailers Social care services Mortgage providers and insurance companies Private rental sector Schools and colleges Retailers and pharmacies Food banks and charities These stakeholders will have to agree on the detailed scope of their shared mission, collectively understand their policies and the wider governance they follow, and characterise the technical systems and services they currently use to support those in vulnerable circumstances. This might mean sharing current organisational policies on vulnerable consumer support and use of instruments such as data sharing agreements and system-level data contracts. To ensure inclusive progress for a broader range of stakeholders, it's important to make this information accessible both to the taskforce and to the public, benefiting a wider audience. Discovery of vulnerable customer registers Several areas of research will need to take place, including collating existing initiatives to coordinate services. Customer registers should be a topic of particular interest. There is no single source of truth for consumer identity between organisations. Energy companies, the NHS, GP surgeries, the DWP, and others all have their own lists; these registers are each operated and formatted differently to one another and will be using identifiers that don’t reliably correlate across organisations. So, a major challenge that the taskforce will face is gaining the technical ability to reliably identify consumers who are in vulnerable circumstances and doing so in a coordinated way across essential service providers. For example, while the NHS number is often considered a reliable identifier, it’s not used universally. An energy company or a bank is unlikely to have its customer’s NHS number. This identification uncertainty is a significant hurdle when attempting to link registers between organisations. Despite the challenge, unravelling the intricacies of integrating different registers to enable consensual identification is a critical step toward creating cohesive and effective essential services. Discovering the exact technical status of essential service providers’ registers is a crucial foundational step that will baseline current capabilities (including learning about register data formats, data quality, data sources, data exchange mechanisms and associated data contracts and service policies). Listing of data sharing agreements and mechanisms As a baseline of existing services and technical systems emerges, the taskforce will be positioned to digest current arrangements and agree on a sector-wide vision for how services across essential service providers should work. We recommend that this vision setting is conducted both at a policy level and on a technical level to ensure that ‘what’ policy agreements plan to achieve is realistic and pragmatic in terms of ‘how’ these plans can be realised. Again, as is our view across the taskforce’s work, we recommend that work is carried out as openly as possible, with progress and plans continually published publicly to ensure inclusivity and trust by the very large ecosystem of stakeholders who will need to coordinate to improve essential services. 2. Design During this stage the taskforce will need to review the assembled information to determine how to adapt essential services for better coordination. We expect this to require a strong focus on both cross-sector policy alignment (such as service requirements across utilities and banks) and data interoperation for technical integration of services. Specifically, the ability to coordinate consumer identification across essential service providers automatically, at a large scale (for millions of people), and in a way that is ethical and fully controllable from the perspective of the consumer is imperative. Focus on data over digital technology will ensure that taskforce solutions are adaptable to suit all stakeholders in the ecosystem (metadata, data spines, data models, API end-point contracts). Review of policy and regulation will help understand where governance is blocking progress or can accelerate investment into what we expect will be a newly emerging standard for ethical personal data permissions sharing. At the design stage, the taskforce will need to create a common data architecture – one that strikes a balance between ensuring a complete service is developed, and preserving the autonomy of participating organisations to get on with building their own services. This means, the taskforce will likely have to agree on the following features for data usage: semantics used when gaining consumer permissions (such as consent) metadata to clarify definitions and align data formats data models to standardise how permissions integrate together data sharing agreements for swift communication to identify people in vulnerable circumstances in operational contexts data policies that pinpoint opportunities to harmonise regulation across sectors Creating these features will help inform the development of a shared data architecture for effective integration of essential services for consumers in vulnerable situations. If the taskforce can achieve this, then it will be ready to move from the initial discovery stage to alpha and beta stage of testing and implementation. 3. Prototype Achieving rapid progress requires prototyping early and often. In our roadmap, we’ve sketched what this might look like, but in reality, the design stage will strongly inform how best to proceed. In general, highly engaged stakeholders should be encouraged to partner and lead on the testing and learning of optimal ways for exchanging data between their organisations. This will allow the taskforce to validate that emerging shared data architecture can scale across an extensible data ecosystem. Implementation will require a shift from the data layer to the digital and technology layers. At this point, proofs of concept (PoC) will be taking centre stage as well as the selection of appropriate tools and solutions. For scalable success, architecture principles should be adhered to, guiding the use of technology. We expect tactical needs to deviate from this and so effective programme management will become key. There will likely be a need to establish ‘run-ahead teams’, comprised of organisations that are developing compatible registers and adhere to the taskforce’s architecture principles. These groups will pioneer data integration approaches and validate that those in vulnerable conditions are better supported across the ecosystem as a result. As PoCs evolve, we expect a growing emphasis on analytical topics, such as techniques for the matching and linking of data sets to identify vulnerable consumers across organisations. Additionally, we also expect the need for test exercises that address specific use cases, such as tracking consenting individuals through their changing circumstances to offer better support as their vulnerability needs evolve. Importance of maintaining a knowledge base We have emphasised the need for the open sharing of taskforce’s progress, but this topic requires further attention. Since a lot of work will be happening in parallel among a very large group of stakeholders, the taskforce needs to be capable of scaling up its own work to sustain progress as more and more essential service organisations participate. So, as the tasks outlined above are getting done, we recommend establishing an open-source knowledge base to communicate progress, developments, and decisions inclusively and quickly as they emerge. This will be complex and require its own governance to achieve coordination at a large scale. Data ecosystems perform best when knowledge is shared between participants. To best respond to this complex social challenge, we recommend knowledge bases are ‘presumed open’ by default for everyone to have open access. Within the knowledge base, the key stakeholders need to be listed, details of the agreed scope documented, existing initiatives summarised, relevant regulations outlined and sign-posted, and the final vision published. In short, the knowledge base should be viewed as a key part of the entire project and continuously added to. It will enable smoother collaboration and a 360° view of the consumer support in essential services landscape. Plus, it’ll improve the ability of the industry and other initiatives to self-service their own efforts, picking up precisely where this taskforce work ends, minimising gaps, and overlap between initiatives. It will serve as a shared blueprint and plan for UK’s essential services sector. Improve support among UK essential services with our experts The current cost of living crisis in the UK has highlighted the urgent need for a more cohesive and effective support system, especially for vulnerable groups. This is a data intensive challenge. The good news is – we can help make sense of the data and facilitate the creation of a reliable ecosystem by enabling relevant organisations to come together, collaborate, and focus on leveraging ethical data sharing to move forward effectively. At Zühlke, we are experienced at addressing the challenges that public sector organisations face and we’re here to help. Our team has already delivered a range of successful public sector digital transformation initiatives, from building the NHS COVID-19 app to helping Innovate UK identify how data can drive decarbonisation. So, if you’d like to understand more about our recommendation, don’t hesitate to reach out, we’ll be happy to continue the discussion and glad to work with you on improving UK vulnerable consumer support in the public sector. 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